End Citizens United Files Second Complaint Against Senator Roger Marshall

The new FEC complaint follows a separate Senate Ethics Committee complaint filed last week

End Citizens United (ECU), a leading national campaign finance reform organization, filed a complaint with the Federal Election Commission (FEC) against Senator Roger Marshall alleging that he used his leadership PAC to pay staff working on his reelection campaign.

The FEC complaint follows a separate complaint ECU filed with the Senate Ethics Committee last week, alleging that Marshall used taxpayer-funded staff, travel, and official resources for campaign and personal purposes in violation of federal law and Senate rules. The new complaint centers on a statement from Brent Robertson, Marshall’s Senate chief of staff and campaign strategist, who said he volunteered for Marshall’s campaign while receiving payments through an affiliated PAC.

“Roger Marshall might want to spend less time worrying about his reelection campaign and more time finding a good lawyer,” said End Citizens United President Tiffany Muller. “His own chief of staff exposed what appears to be an illegal scheme by Marshall to use the leadership PAC to subsidize his reelection campaign. Federal law expressly prohibits this kind of arrangement, and calling it volunteer work doesn’t change that. We thank Brent Robertson for bringing this serious matter to our attention. We couldn’t have done it without him”

According to the Kansas Reflector, “Robertson and Fuller said they were volunteers for Marshall’s campaign, and Robertson said he was paid through an affiliated PAC. Campaign finance reports show Robertson was last paid through the PAC on Jan. 28, when he received $33,000 for “strategic consulting.”

FEC records show that Marshall’s leadership PAC, Defend Our Conservative Senate PAC (DOC’s PAC), is the only political committee that has paid Robertson. Since January 2025, DOC’s PAC has paid Robertson $66,200 for “strategic consulting,” including $33,000 on January 28, 2026. Since January 1, 2021, DOC’s PAC has paid Mr. Robertson a total of $194,570 in consulting fees, while the campaign has not paid him a single penny since June 2021. Federal law prohibits Marshall from using his leadership PAC to subsidize his reelection campaign beyond the applicable contribution limit of $5,000 per election.

The Complaint:

Mr. Robertson is Senator Marshall’s chief of staff, a position he also held in Senator Marshall’s House office, and until recently he reportedly “headed campaign operations” for the Campaign. On October 21, 2026, reporting on the Ethics Complaint, the Kansas Reflector wrote: “Payton Fuller, a spokesperson for Marshall’s office and campaign who appears in the letter, did not respond to Kansas Reflector’s request for comment for this story. Robertson and Fuller said they were volunteers for Marshall’s campaign, and Robertson said he was paid through an affiliated PAC. Campaign finance reports show Robertson was last paid through the PAC on Jan. 28, when he received $33,000 for “strategic consulting.”
The “affiliated PAC” Mr. Robertson referred to can only be Senator Marshall’s leadership PAC, Defend Our Conservative Senate PAC (DOC’s PAC). FEC disbursement records for the 2025–2026 election cycle show that DOC’s PAC is the only political committee that has paid Mr. Robertson, including the $33,000 payment for “strategic consulting” on January 28, 2026.
The FEC has stated that contributions received by leadership PACs are “given to other Federal candidates to gain support when [an] officeholder seeks a leadership position in Congress, or are used to subsidize [an] officeholder’s travel when campaigning for other Federal candidates.” Federal candidates may not use their leadership PACs to finance their own campaigns: a leadership PAC may not donate or otherwise provide more than $5,000 in goods and services per election to the Federal candidate with whom it is associated.
Federal law defines a “contribution” to include “the payment by any person of compensation for the personal services of another person which are rendered to a political committee without charge for any purpose.” These in-kind contributions must be reported by the recipient committee and count against the payor’s contribution limits. The exception for volunteer activity, by contrast, covers only “services provided without compensation by any individual who volunteers on behalf of a candidate or political committee.” A multicandidate political committee such as DOC’s PAC may contribute no more than $5,000 per election to a candidate. A candidate committee may not knowingly accept a contribution in excess of that limit.
Senator Marshall’s chief of staff has effectively confessed that DOC’s PAC made, and Kansans for Marshall knowingly accepted, an excessive and prohibited in-kind contribution. As the Kansas Reflector reported: “Robertson and Fuller said they were volunteers for Marshall’s campaign, and Robertson said he was paid through an affiliated PAC.”
Even though he “headed campaign operations,” the only political committee that has paid Mr. Robertson this cycle is DOC’s PAC. Mr. Robertson’s own words establish every element of an illegal contribution: he works for the Campaign, the Campaign does not pay him, and DOC’s PAC does. That is precisely “the payment by any person of compensation for the personal services of another person which are rendered to a political committee without charge.” Calling Mr. Robertson a “volunteer” changes nothing. The volunteer exception covers only uncompensated services, and Mr. Robertson, by his own admission, is paid by Senator Marshall’s leadership PAC for his Campaign work.
DOC’s PAC’s disbursement records confirm this. Since January 2025, DOC’s PAC has paid Mr. Robertson $66,200 for “strategic consulting,” including $33,000 on January 28, 2026, the year Senator Marshall faces re-election. The January 2026 payment alone is more than six times the $5,000 per-election limit on contributions from DOC’s PAC to the Campaign; the cycle’s payments together are more than thirteen times that limit. And these payments are part of a longer pattern: since January 1, 2021, DOC’s PAC has paid Mr. Robertson a total of $194,570 in consulting fees, while the Campaign has not paid him a single penny since June 2021.
The available evidence clearly indicates that Senator Marshall has used his leadership PAC to subsidize the Campaign by paying its chief strategist, whose services the Campaign was legally required to pay for itself. It is improbable that this was a mere oversight by Senator Marshall. He has been a Federal candidate under these same rules for multiple election cycles, and the reporting shows him and Mr. Robertson flagrantly disregarding federal law and Senate rules.

Click here to read the full FEC complaint.

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For 11 years, End Citizens United (ECU) has been dedicated to combating the two biggest challenges facing our democracy: the corrosive impact of Big Money in politics and attempts to block access to the ballot box. Since its founding in 2015, ECU has had over 1.4 million donors with an average donation of just $14. The group has more than four million members nationwide and is one of the nation’s leading anti-corruption organizations.